Calfee, Halter & Griswold Partner Patrick Hayes Co-authors

Cincinnati, Jan. 19, 2022 (GLOBE NEWSWIRE) — Patrick D. Hayes, partner and principal of the law firm Calfee, Halter & Griswold LLP and member of the board of directors of the National Society of Compliance Professionals (NSCP), has recently co-authored The NSCP Firm and CCO Liability Framework, a guide offering a practical approach to the topic of Chief Compliance Officer (CCO) liability.

“As the premier financial industry organization that educates and advocates for compliance professionals, the NSCP has recognized its unique position to examine the practical challenges faced by CCOs within the broader governance structure of entities. regulated and provide context that went beyond the technical aspects of compliance as it relates to CCO’s liability,” said Hayes.

As a member of the NSCP’s Regulatory Advisory Committee, Hayes and the other co-authors have examined the issue of CCO liability over the past year and assisted the NSCP by conducting surveys of its more than 2 000 members to gauge their views on CCO accountability, empowerment and resources. .

“The survey results were incredibly informative and provided the basis for the Regulatory Advisory Committee to develop the accountability framework for NSCP and CCO,” said Hayes.

The NSCP Firm and CCO Liability Framework (“NSCP Framework[1] “) provides a practical approach to the subject and complements an earlier New York City Bar Association publication titled New York City Bar Association White Paper on CCO Liability.[2] The NSCP Framework is intended to be read in conjunction with the New York Bar Association White Paper to provide a realistic perspective on CCO liability issues while promoting investor protection and market integrity.

The NSCP framework states: “To more effectively address the issue of CCO liability, the NSCP believes there is a need to focus on the broader context of the compliance function within companies and to do so earlier. in regulatory reviews, whether during reviews or enforcement investigations. A copy of the NSCP Firm and CCO Liability Framework guide provides additional details.

In 2020, Hayes launched The Securities Compliance Podcast: Compliance in Context™, co-sponsored by Calfee and the NSCP. In episode 10 of the podcast, which aired in January 2021, Securities and Exchange Commissioner Hester M. Peirce joined Hayes to talk in depth about the issue of CCO liability.

The NSCP thanks Commissioner Peirce for helping to provide the spark that led to the Regulatory Advisory Committee taking over to develop the NSCP Framework.

“Commissioner Peirce has been instrumental in advancing the conversation on CCO’s accountability, and we welcome continued dialogue with her and the rest of the Commission on this important topic,” said Lisa Crossley, Executive Director of NSCP.

With 7,600 listeners in 2021, The Securities Compliance Podcast: Compliance in Context was named “Top 20 Securities Podcast of 2021” by Welp Magazine.


Calfee, Halter & Griswold LLP is a full-service law firm with 160 attorneys and six offices in Cleveland, Columbus, Cincinnati, Indianapolis, New York and Washington, D.C. Calfee has been recognized as a leading law firm by the Chambers USA Legal Guide 2021 in the areas of antitrust, banking and finance, corporate/mergers and acquisitions, benefits and executive compensation, general commercial litigation, insurance, intellectual property, labor and employment, natural resources and the environment, and real estate and through the Guide Chambers High Net Worth 2021 in private wealth law. The firm serves clients in the Midwest, nationally and globally in the areas of corporate restructuring and insolvency, corporate and financial, employee benefits and executive compensation, energy and utilities, estate and estate planning and administration, government relations and legislation, intellectual property, labor. and Employment, Litigation and Real Estate. A founding member of Lex Mundi, Calfee provides international representation through a network of independent law firms with access to 22,000 attorneys located in over 125 countries. Additional information is available on


The National Society of Compliance Professionals is a nonprofit organization dedicated to serving and supporting compliance professionals in the financial services industry. Membership in the NSCP provides financial services compliance professionals with a wide range of resources, including a community of like-minded peers, ongoing education to deepen their knowledge and specialist skills, and regulatory involvement through consumer representation. compliance interests. Over 30 years since its inception, the NSCP has grown to over 2,000 members with a plethora of educational offerings and networking opportunities for its members. Additional information is available at




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